ease of doing business in the

Ease of Doing Business in the Gems and Jewellery Industry

BULLION FEDERATION


July 2018

Authors:Nirupama Soundararajan

Senior Fellow, Pahle India [email protected]

Arindam GoswamiFellow, Pahle India Foundation

[email protected]

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1: Overview ....................................................................................................................7

2: Mining ......................................................................................................................10

2.1 How to Mine and Where to Mine? 11

2.2 The Problem of Gold Ore Tailing 11

2.3 Policy Issues 12

3: Refining ....................................................................................................................13

3.1 Renewal of License for Accreditation Process by NABL 13

3.2 Sourcing: Financing Gold Business and Non-Availability of Gold from Gold Aggregators 14

3.3 Non-Availability of Dore on Consignment 15

3.4 BIS Requirement for Dore Import 15

3.5 Accreditation 15

3.6 Hedging on Exchange 16

3.7 Export of Industrial Products 16

3.8 Import of Finished Products as Zero Duty, under ICGRME 17

3.9 Import of Items under Chapter 2843 and 381512 of Customs at 7.5 per cent 18

3.10 Need Support for Export of these Products 18

3.11 Proof by Data 18

3.12 Definition of Dore 19

3.13 The Case of Rural Refineries 19

4: Bullion Dealing .........................................................................................................20

4.1 Procurement and Distribution 20

4.2 Trade on Commodity Derivatives Market 21

4.3 Problems of Smuggling 21

4.4 Taxation Related Issues 21

4.5 KYC Norms 21

Contents


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5: Manufacturers and Wholesalers ...............................................................................22

5.1 Procurement of Raw Material 22

5.2 Business of Manufacturer 23

5.3 Billing Problems 23

5.4 Gold Metal Loan (GML) and Its Advantage 24

5.5 Quality Check and Hallmarking 24

5.6 Export Problems 25

5.7 Consignment Delivery and Logistical Problems 25

5.8 Cost of Exhibitions 25

5.9 Margins for the Industry 25

5.10 Lack of Skilled Karigars in the Industry 25

6: Karigar Community ..................................................................................................26

6.1 Karigar Business – An Introduction 26

6.2 Way it Works 26

6.3 Investment in Business 27

6.4 Procurement of Raw Material and Calculation of Karigar Fee 27

6.5 Challenges in the Business and Recommendations 28

7: Retail Jewellers.........................................................................................................30

7.1 Introduction of the Retail Jewellery Business in India 30

7.2 Sale and Billing 30

7.3 GST and Taxation 31

7.4 Prevention of Money Laundering Act (PMLA) 31

7.5 Hallmarking 31

7.6 Reputation Crisis 32

Annexures .....................................................................................................................33

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1.1 IntroductionThe role of the private sector is a key driver of economic growth and development. The abundant potential of this sector to generate employment makes it increasingly significant for the overall growth of the nation. However, like most developing nations, Indian businesses face several challenges. A predictable regulatory environment and effective business regulations are critical for market development and businesses to thrive. Moreover, role of governments is key to establishing these well-functioning markets through regulation. Effective business regulations can encourage start-ups and minimize the chance for market distortions or failures. The demographic dividend coupled with the incumbent government’s focus on making India a nation driven by competitive

business climate, places India in a very promising position.

The private sector and government are cornerstones of an economy that cannot exist in isolation. While advocating complete control to private sector would result in inequitable social matrix, excessive regulations bear the risk of adversely impacting ease of business. We need to strike a fine balance by making smart regulations that would create a conducive business environment, and at the same time, provide adequate protection to consumers and other societal participants. As a first step, there have been significant developments towards ensuring a favourable business climate for domestic and foreign investors. Increasing foreign direct investment (FDI) limits through automatic route for most sectors makes India an attractive host economy.

1: Overview


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Having said this, sectoral growth does not always reflect the improvements in rankings for ease of doing business (EoDB). In fact, until recently, the rankings did not take into consideration user experience. Business feedback is critical to ensuring that the reforms that have been implemented are being felt by the private sector1. Therefore, DIPP has recently started carrying out a comprehensive business-to-government (B2G) feedback exercise. States and union territories (UTs) take feedback from businesses on the quality of implementation of the reforms claimed. The first set of results of this are yet to be made public. An expected limitation of this process is that business feedback will only be a collation of feedback from across sectors. For a more detailed review, it is necessary to deep dive into the feedback process. This could be done by randomly selecting a set of businesses, which is not unlike what Department of Industrial Policy and Promotion (DIPP) intends to do. Alternatively, a more robust methodology would be to do this sector-wise.

1.2 The Importance of Bullion in IndiaThere is consensus that the demand for gold is not likely to reduce. The recent Reserve Bank of India (RBI) report on household savings pegs the average household holds an average of 11 per cent in gold. The report also states that in the coming years, the demand for gold is only likely to increase. This is not surprising. Gold is and will continue to be a trusted source of domestic savings, more so in rural India. The report attributes this choice to the lack of trust in financial institutions.

Recent demand trends suggests that urban demand for gold may be paring down. The educated younger generations are less inclined to buy heavy jewellery. Access to other financial savings products also reduces the demand for gold. Notwithstanding this, economic growth does drive up disposable income which in turn is likely to drive up the demand for gold in low and middle income groups, even if not in the higher income groups. Gold will always be viewed as a safe asset, with store of value and an effective hedge against inflation. By design or coincidence, the average Indian buys gold for the same reasons that the Reserve Bank of India (RBI) buys gold and this characteristic of the average Indian is unlikely to change dramatically in the coming years.

If one accepts the reality of a growing demand for gold, not necessarily because of an increase in per capita consumption, but because of economic growth and wealth creation, a comprehensive gold policy is essential. Public discourse has suggested many objectives for the gold policy. One such important objective is to ease doing business for those in the bullion business.

1.3 The Gold Value ChainThe gold ecosystem is a complex one. There are a variety of stakeholders and many kinds of business relationships between each stakeholder. In order to evaluate the ease of doing business in the bullion industry, as a first step, we plotted the value chain. For the purpose of this study, we have chosen to only consider those stakeholders whose livelihoods depends on gold, that is, we have not examined the ease of doing business for financial institutions. This

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is because the concerns of the financial institutions have been elucidated as part of the objective of financialisation of gold.

We conducted multiple semi-structured interviews with various members of the value chain to seek their

opinion, inputs, and suggestions on how easy it truly is to do business in the bullion industry and what are some of the immediate changes that can make doing business easier.

Figure 1: Flow of Gold in the Gems and Jewellery Industry

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Figure 1: Flow of Gold in the Gems and Jewellery Industry

Overseas Supplier

Mines

Domestic Refinery

Importing Banks

Star Trading

Unit

Bullion Dealer Retail Jeweller

with In-house Manufacturing

Manufacturer & Wholesaler

Karigar

Retail Jeweller & Corporate

Sellers

Hallmarking Agency

Retail Investor & Consumer

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The global demand for gold is 4000t whereas production of gold is between 2000t and 2500t. Thus there is a worldwide demand supply gap of almost 2000t. Most of the gold produced today is mined in South Africa, Australia, Ghana, Peru, Canada and China. Gold mining in India dates back to as early as 1st century BC. Currently it is limited to a single functioning gold mine in India. After the Kolar Gold Field closed down in 2001, gold mining in India fell drastically. Furthermore, the closing of the Kolar gold mine has caused the Government a liability of INR 16,000 crore. Currently, Hutti Gold Unit (HGU), in Raichur district is the only gold mine that is operational in the country. The Hutti Gold Mines Company Limited (HGML), a public sector unit (PSU) under the Government of Karnataka, is responsible for mining gold in that area. Currently, the ore from Hutti

mine is also supplemented by satellite feeds from the Uti (opencast) and Hira-Buddinni (exploratory underground mine) deposits. It appears that since it restarted its operation in 1947, HGU has produced 94t of gold on 1500 hectares area. Availability of gold deposits have been reported in areas such as Tumkur, Shimoga, Avasi, and Dhawangiri in Karnataka. The possibilities of gold reserves across 40,000 hectares is immense. The Geological Survey of India (GSI), Mineral Exploration Corporation Limited (MECL) and Ministry of Mines (MoM) only need to produce quality geo scientific data and accelerated permitting within 2 years and quality explorers and expert miners are more likely to come and invest funds and resources to explore and develop the many available gold projects in India.

2: Mining

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Currently, most mines in our country are under the control of Government. The Mines and Mineral (Development and Regulations) Act of 1957 commonly known as the MMDR Act, states that a State Government can sanction up to 1000 hectares land for mining and exploration. Beyond 1000 hectares, it is the responsibility of the Union Government. Approval for the sale of a mine has to be given by the State Government, who in turn needs to take the permission of the Central Government and the Pollution Control Board apart from clearances from other concerned ministries.

2.1 The Problem of Mining Licens-es?Gold mining has occurred in India over the last 6000 years with more than 900 known gold prospects. However investment in gold exploration over the past 20 years has been negligible. Currently, most mines in our country are under the control of Government. A gold miner has to procure three separate license for gold mining:

a. Reconnaissance License (RL)b. Prospecting License (PL)c. Mining License (ML)

The Government of India has granted many Reconnaissance Permits for precious metal exploration but only a few have progressed to a Prospecting Licence and only one converted into a Mining Lease after securing 130 approval that took more than 8 years. The state government issues PL for less than 1000 hectare, whereas Central Government gives the permission for more than 1000 hectare. The same applies for ML too. A PL is issued for one

specific company which is non-transferable. Hence, collaborations are difficult to achieve.

2.2 The Problem of Gold Ore Tail-ingGold principally occurs as a native metal. One tonne of ore produces about 3g of gold while an estimated amount of 6 lakh tonnes of ore is processed every year. The process of extraction of gold from the ore needs cyanide. After the extraction of gold the residual product remains. This is called the gold dump or the gold ore tailing (GOT). The GOT often is absorbed in the earth and also spreads to surrounding areas through rain, air, water etc. This contaminates water level and is often a major environmental problem. If GOT is not treated appropriately it will render the area inhabitable.

The problem of GOT can be solved by using them in road building material, bricks kiln etc. Currently, this proposal is pending with the Central Pollution Control Board and the State Pollution Control Board for last 3 years.


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2.3 Policy IssuesCurrently, there is no dedicated gold mining policy in India. To increase India’s domestic gold production capability it is important that gold mining be undertaken in India. This calls for formulation of a dedicated gold mining policy for India. The gold mining policy must focus on the need to address the following issues:

a. Suitably amend the MMDR Act to make concession for gold mining.

b. The information on total area available for gold mining, area under reconnaissance in various parts of the country should be published and made public from time to time.

c. Formation of a single window clearance for issuing various license. The Government may also explore the option of delicensing some of the processes.

d. The policy should clearly state if gold mines can auction specific areas or progressive rates can be fixed on gold they mine over the year. Alternatively, the Government should think if the mines can be privatised completely or given to private players on profit sharing basis.

e. The state government may also look at setting up a public sector unit (PSU) in designated areas in a time bound manner that may be further expand as the need arises. This will ease the regulatory process and remove the pressure off a single company.

f. Central and State Pollution boards will have to be more proactive in issuing approvals for waste management for gold mines.

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The gold refining sector in India has undergone a drastic change in the last few years. From a mere one or two odd registered refineries in 2011, our country today has more than thirty registered refineries across India. In fact, more than 10 per cent of our domestic consumption of gold is met by the refineries through gold recycling.

3.1 Renewal of License for Accreditation Process by NABLTo renew its license from NABL a domestic refinery needs to follow the following procedure.

1. First the refinery needs to apply to NABL for an audit.

2. Then the refinery needs to carry out an internal audit and send the report to NABL.

3. Once the internal audit reports reaches NABL, an auditor is appointed within a period of 30 days.

4. The auditor visits the premises one month later.

5. The auditor goes thoroughly through every process and identifies issues, if any.

6. Once issues are identified, corrective actions are taken and the audited report is sent to the NABL

7. The audit report is presented to a committee formed at NABL, where the final decision for renewal is taken although uncertainties exist till the end.

8. In case, the audit committee is not satisfied with the report, another month is given to rectify the issues.

3: Refining


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9. In case the refinery fails the subsequent audit process, then committee decides what is to be done. During our interview with the refiners it was found that it is unclear what happens if the license is taken away i.e. whether the refinery can continue to refine or not.

10. The NABL audit is linked largely to import of dore by the refineries from mines abroad.

3.2 Sourcing: Financing Gold Busi-ness and Non-Availability of Gold from Gold Aggregators Precious metals like gold, platinum, palladium are available in limited quantities naturally. Even when found, they are typically in the range of 3-8 g/t compared to commodities like copper, aluminium which can be obtained for about 200-600 kg/t. Hence exploration and mining of precious metals is costly. It is natural that the financing requirements for this kind of business is more uanced. The top gold mines of the world (especially in Latin America and

Africa) are mainly owned by North American and Australian companies. The reason being, that in these continents they have specialised bullion banks and institutions which focus on the business of evaluating mines, financing such activities, and also trading in the finished products. As a result of this almost all the output of these large mines is controlled by such financial institutes. Further, these banks often get the gold refined and valuated in LBMA accredited refiners around the world. The cost of financing is does not come cheap. For most economies of scale justify the cost or help lower the cost of finance substantially. However, the smaller refiners are not in a position to source from the big mines, because obtaining long term contracts or cheap financing is almost impossible.

The small and medium Indian refiners can therefore only source gold from small artisanal mines. Our discussions revealed that most of the small mines and artisanal mines do not have proper melting and assaying facilities in their remote mining location. Access to these mines is not easy either. In order to assist the export of such gold most local governments have authorised aggregators who aggregate the dore from various small mines, smelt it, assay the aggregated dore and export it to the refineries abroad. This aggregated dore is refined abroad and find its way to India through nominated agencies. However, the Indian refiners are not able to import this aggregated dore due to specific conditions attached to import of dore. The Indian government does not recongnise government approved and regulated aggregators in the mining company. Hence the cost of procuring dores directly from the mines in small quantity proved to be an expensive task.

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Indian refiners must be allowed to source gold from aggregators who are accredited and/or regulated by their home country.

Currently, refineries in India can source gold either from domestic mines or authorised foreign mines abroad. To boost domestic refineries and create a level playing field with international refineries it is imperative that domestic refineries are allowed to source from foreign aggregators.

3.3 Non-Availability of Dore on ConsignmentAs pointed in point earlier that most of the financial institution vault the gold at various refiners and other institutions. Even in India they are able to provide pure gold to nominated agencies on consignment basis, since the duty on gold is a tariff value. In order for these institutions to vault gold in Indian refineries it is required that the custom duty is fixed as tariff

value for dore as in the case of pure gold instead of the assessable value.

3.4 BIS Requirement for Dore Im-portTo import dore a refiner need to get license from Directorate General of Foreign Trade (DGFT) under the Ministry of Commerce and Industry. The latest rules as per Circular no. F.No. 01/53/162/Misc/AM17/PMO/M-4/IC issued by DGFT requires that the refiners are BIS certified. Additionally, Revised Policy of Licensing Gold Refiners issued by BIS states that:

This leads to a catch twenty two situation for new refiners or small refineries trying to import dore. The DGFT permission for import of dore requires that the refiners have BIS certification. To get BIS certification the refinery should operate for one year. This would imply that the only source of gold would be domestic gold available for recycling. This means that for atleast one year a refinery will have to forcefully work way below capacity. To push investment in new refineries in India or encourage unorganised refineries to be organised, it is needed that the BIS certification requirement and gold import be delinked.

3.5 AccreditationPresently, registered refineries in India needs to undergo two distinct certifications i.e. the National

Existing condition No. 34 of notification No.50/12 – Customs dated 30th June 2012 specifies:

Condition 40 (b) – the goods are imported in accordance with the packing list issued by the mining company whom they were produced

It is suggested that this is amended as

“…the good are imported in accordance with the packing list issued by the mining company or by the authorised exporter located in the same country of origin.

2. a) The refinery is in operation for at least one year as on the date of making application to BIS


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Accreditation Board for Testing and Calibration Laboratories (NABL) certificate for the certification of the process of refining and the Bureau of Indian Standards (BIS) certification to allow the use of seal for marking of gold and silver bars. The refineries are of the opinion that the BIS marking must not be mandatory for refining of gold. In fact the process of accreditation should not be government driven and rather industry driven.

3.6 Hedging on ExchangeIn India, oil refineries are allowed to hedge on COMEX and other international derivative exchanges. However under Foreign Exchange Management Act

(FEMA) Indian gold refineries are not allowed to hedge on foreign exchanges. Since gold refineries are not allowed hedge on international exchanges their price risk increases drastically.

3.7 Export of Industrial ProductsA large quantity of precious metal like gold, platinum and palladium are used for industrial purpose. As can be seen from above graph, globally 12 per cent of gold is consumed in industrial applications. Moreover, with the rising number of electronic devices this is likely to increase in the future. The products that fall under this are:

Annual gold demand by category in tonnes (2012-2016 average)

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3.6 Hedging on Exchange In India, oil refineries are allowed to hedge on COMEX and other international derivative exchanges. However under Foreign Exchange Management Act (FEMA) Indian gold refineries are not allowed to hedge on foreign exchanges. Since gold refineries are not allowed hedge on international exchanges their price risk increases drastically. 3.7 Export of Industrial Products Annual gold demand by category in tonnes (2012-2016 average)

Source: Metals Focus; Thomson Reuters GFMS; World Gold Council

A large quantity of precious metal like gold, platinum and palladium are used for industrial purpose. As can be seen from above graph, globally 12 per cent of gold is consumed in industrial applications. Moreover, with the rising number of electronic devices this is likely to increase in the future. The products that fall under this are:

a) Precious metal chemicals which are defined under HSN CodeNo.2843. b) Industrial Products (Chapter 7115) out of Precious Metal (Gold, Silver

Palladium etc.) for Industrial use. c) Catalyst which are made from Palladium and Platinum which are defined in

HSN 381512.

Source: Metals Focus; Thomson Reuters GFMS; World Gold Council

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a) Precious metal chemicals which are defined under HSN CodeNo.2843.

b) Industrial Products (Chapter 7115) out of Precious Metal (Gold, Silver Palladium etc.) for Industrial use.

c) Catalyst which are made from Palladium and Platinum which are defined in HSN 381512.

The irony is that we have the capability of manufacturing many of these products in India, but India is not a major supplier of these products. This is a major reason for the negligible growth of the local industry in the India compared to China. Further, it cannot be emphasised that local supply of product to technology industry is important for the security of the nation.

The above products are manufactured from precious metals such as gold, silver, palladium and platinum. They are of high value (since the value of precious metals is inbuilt), and the value addition at the end of the manufacture is in the range of 1per cent to 2 per cent. Consequently, there is a very thin profit margin. Moreover, all the precious metals used to manufacture these products suffer basic custom duty (BCD) of 10 per cent.

It was found that at present, industrial product exports of gold are not treated as finished goods. Industrial uses are products which are not for jewellery, for example electroplating, parts for automobiles, reflectors, medicinal purposes, water purifying components and so on. Due to this there is no duty drawback on the same. This creates an unlevel playing field between gold jewellery meant for export and gold based industrial products which too are finished products. To promote export of finished gold based industrial products it is important that these should also be treated at par with jewellery. This will be in the true essence of Make in India programme. Moreover, this is an easy way to plug into global supply chain.

3.8 Import of Finished Products as Zero Duty, under ICGRMEAnnexure 1, shows few extracts from the list of goods that can be imported at zero BCD under the Import of Goods at Concessional Rate of Duty for Manufacture of Excisable Goods (IGCRME) scheme. Import of goods under IGCRME at zero BCD works out cheaper then local manufacture, since local manufactures have to pay 10 per cent BCD on the raw material such as

Precious Metal BCD Notification

Gold 10% Cus 50/2017 Sl. No 356

Silver 10% Cus 50/2017 Sl. No. 357, 359

Platinum 10% Cus 50/2017 Sl. No. 363

Palladium 10% Tariff Rate


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gold, silver etc. Moreover, since the value addition is just 1 per cent to 2 per cent, the local manufacturers cannot compete against these imports. This is against the interest of the local industry and needs to be corrected.

3.9 Import of Items under Chapter 2843 and 381512 of Customs at 7.5 per centThe finished product of the above HSN can be import-ed at BCD of 7.5 per cent whereas the local industry needs to pay custom duty of 10 per cent on raw mate-rial while working on a thin margin of 1-2 per cent. This too is against the interest of the local industry and the situation needs to be corrected.

3.10 Need Support for Export of these ProductsThere is a good potential for exporting these products. However, to enable export of these products from India it is required that facilities such as the ones provided to jewellery exporters such as advance au-thorisation, replenishment, Gold Metal Loan (GML) at international rates and a reasonable value addition of 1 per cent to 2 per cent norm are allowed. We request that the new Foreign Trade Policy (FTP) extends these facilities to these other products of precious metals.

The drawback for these products is not provided in many cases and in case provided it not sufficient. There the exports are not viable.

3.11 Proof by DataPreviously when the duty on precious metal was about 1 per cent (prior to 2012), many of these products were supplied by the local industries. This changed after the duty was increase in 2012 in stages to 10 per cent. This is evident from the data presented in Annexure -2.

It is suggested by the refineries that to have a structure such that the local industries using this product, source the same from Indian manufacturers by providing a lev-el playing field with the imports. This can be done by:

i) Remove the products (2843 and 71) from the IGCMRE and increase duty in Cus 50/2017 for HSN 2843 and 3181215 to 10 per cent

OR

ii) Reduce custom Duty on the raw material to zero

OR

iii) Any other change which provides a level playing field to the local manufactures with the international players so we can become a hub for production of such products.

HSN code BCD (%) Notification

28 7.5% Cus 50/2017 Sl. 169

3812 7.5% Cus 50/2017 Sl. 250

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3.12 Definition of DoreCurrently, dore is undefined in India. Indian customs define anything above 2 per cent gold in it as gold. Internationally, the purity of dore can vary anywhere between 60 per cent and 95 per cent. As per Cus-toms, if the percentage of gold in a dore is above 95 per cent it is termed as bullion. It is to be understood that if refiners are allowed to import dore, there must be some kind of value addition that must happen to it or else, it is the same as importing gold. Hence, gold dore needs to be defined. In fact the value addition should also be defined in the policy which should essentially mean not only a physical change but also a change in the chemical composition. Our interviews with refiners suggest that the difference of dore and pure gold in international market is USD 2- USD 3 per ounce. The difference in the customs duty of dore and finished gold should be at least 2 per cent, so that the refiners can get some benefit out of this.

3.13 The Case of Rural RefineriesInitially, the Government had ordered that for manu-facturing in rural areas there will be excise duty ben-efits. With GST this benefit is lost. This has resulted in

increase in transaction costs, logistical cost, problems in accessing raw material, higher cost of insurance for those refineries in rural India when compared to those in metros or tier one cities. The idea of setting up small refineries in rural India is important, espe-cially in the context of gold monetisation. For this, a different kind of incentive must be provided to ensure that these refineries in rural India not only stay in business, but also new refineries to come up.


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4.1 Procurement and DistributionBefore banks and import houses were given license to import gold, bullion dealers were the designated gold suppliers in the country. However, after nominated banks and Star Trading Houses (STH) were allowed, bullion dealers started importing gold and silver through these institutions. Bullion dealers do not need any kind of registration to start a business unless it is a LLP or a private limited company. Only a GST registration is needed which done under HSN 7108 (for gold) and HSN 7106 (for silver).

To import gold, a bullion dealer has to give an intent of purchase to the importing bank or an importing agency. On receiving it, the importing bank/agency brings the consignment and deposit it in authorised vaults. The consignment period is typically for 30 days. The importing bank/agency takes only the margin money. Typically, an average consignment

varies from 100kg to 200kg although the minimum consignment size is 50kg. Domestically, bullion dealers also source from domestic refineries. During our interviews, bullion dealers informed that there is a difference between the prices of gold procured from London Bullion Metal Association (LBMA) certified refineries and local refineries selling Indian gold. The LBMA certified refineries sells gold at a premium of 1000 to 2000 rupees a kilogram. It has been recommended that standardisation be brought into the process of refining in the country.

The bullion dealer adds his premium over and above Goods and Services Tax (GST) on Carriage and Insurance Paid (CIP). Usually, the premium is INR 500 per kilo of gold. The bullion dealers usually sell gold to jewellers (manufacturer and karigar both) and to retail participants (investors). Large bullion dealers even sell to smaller bullion dealers. These smaller dealers are also known as sub dealers. 90 per cent of

4: Bullion Dealing

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the sales is done to jewellers although some amount of gold is sold to private investors. Bullion dealers sell gold for as low as 1g. On an average, 5kg to 10kg gold is sold on a daily basis. Retail customers (investors) do not tend to sell their gold back to bullion dealers as they lose out the GST paid. Bullion dealers were also of the opinion that the general rate of investment in gold has gone down among retail participants over the years as savings in gold per se has gone down or has shifted to financial products.

4.2 Trade on Commodity Deriva-tives MarketMajority of bullion dealers claimed that they had earlier traded on MCX futures market for hedging purposes. However, after imposition of Commodity Transaction Tax (CTT), almost all bullion dealers moved out of exchange as cost of transaction became much higher. Many even claimed to know of people moving to the illegal dabba trading because of CTT. Almost all those trading on MCX earlier agreed that they would return to trading on exchange if CTT is removed.

4.3 Problems of SmugglingMost bullion dealers complained that smuggled gold sale is one of the biggest menace in bullion dealing business. Smuggled gold sells at a lower price than imported gold on account of no import duty. In order to decrease smuggled gold in the ecosystem, two suggestions were made. First, import duty of gold must be lowered to make legally sourced gold cheaper than it currently is. Second, a mechanism must be developed to track the sale of legal gold. It was suggested that GST data be used to track the sales of illegal gold. Business to Business (B2B) data

can be used to find the gold in the market while Business to Consumer (B2C) data can help track subsequent sales of gold.

4.4 Taxation Related IssuesAnother major problem faced by the bullion dealers is that of tax harassment by income tax (IT) official. On most instances IT officials assesses the taxes on the basis of presumed margins even though actual margins are far lower. For example, in most cases the bullion dealers has to sell imported gold at as low as 0.5 per cent margin so as to match the competitive rates of smuggled gold. However, IT officials would assume the sales margin to be 1.0 per cent thus assuming that bullion dealer is trying to evade taxes.

An interesting problem which has recently emerged in the bullion dealing sector is due to GST. After imposition of GST, due to a uniform taxation policy, the demand for gold has gone up in the manufacturing bases of gold jewellery such as Kolkata, Coimbatore, and Mumbai etc. resulting usually in a fall of sale in non-manufacturing hubs.

4.5 KYC NormsIt was suggested that even though consumers submit Know Your Customer (KYC) documents for purchasing gold, there is no way to cross check and validate the same by bullion dealers. Appropriate, system should be put in place to cross check KYC details as the onus of appropriate KYV lies with the bullion dealer. For businesses that typically deal in high value transaction every day, notwithstanding whether the monies are paid through cash or through digital means, a robust KYC documentation validation mechanism for both individuals and businesses must be set up.


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Commonly manufacturers are the bulk producers and wholesalers of the gems and jewellery industry. Usually, manufacturers do not sell directly to retail customers and rather sell their jewellery to retail jewellers and corporate clients, although few manufacturers do have showrooms for sale to retail customers. For a manufacturer registering as a MSME or SSI certificate allows for easier paper work.

5.1 Procurement of Raw MaterialManufacturers procure gold from banks and bullion dealers. Typically, procuring through banks works best when one has to take delivery in bulk. That means the quantity may range anywhere between 15 to 20 kilogram at an unfixed price. This may be done either through the Gold Metal Loan (GML) or through outright purchase on consignment basis.

For procurement of smaller quantities, buying from bullion dealers works best as they sell even 1 to 2 kilogram, for which the price is fixed on spot. Some banks are averse to offering GML for small quantities since economies of scale will not work. Generally, the rate of interest of GML is around 6 per cent and gold can be obtained immediately. The advantage of GML over outright purchase is that price can be fixed in 6 months and only interest has to be paid reularly. Our interviews also revealed that most manufacturers avoid trading on commodity derivatives exchange such as MCX as people start speculating on derivatives market. On being asked about trading on the recently announced spot exchange manufacturers told that they are open to trading on spot exchange provided that the procedure for trading is not complicated.

5: Manufacturers and Wholesalers

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5.2 Business of ManufacturerOnce gold has been obtained, it is distributed to karigars who typically would take 10 to 15 days toc convert gold into jewellery, depending on the quantity, type, and style of jewellery. Karigars are artisans who are employed on job work basis. The manufacturers do not sell gold to karigar but supply them with gold as raw material. Once the ornaments come back in finished form this is kept as inventory at the manufacturers’ storage facility/locker. Generally, a manufacturer may have around 50 kg inventory at any point in time.

Corporate clients and retail jewellers visit shops and select specific styles and designs as per their choice. Generally, all corporate clients and jewellers have tie ups with a hallmarking centre. On selection of the jewellery, the corporate client or retail jeweller request the manufacturer to hallmark all the jewellery pieces by their preferred hallmarking centre. Once the jewellery is stamped and marked by the hallmarking agency, the jewellery is sent back to the manufacturer.

On receipt of the jewellery, the manufacturer will make an invoice for the amount which the corporate client or retail jeweller will pay for and take the jewellery. All manufacturers and karigars have their own seal on a piece of jewellery. Hence each store knows which manufacturer the jewellery came from. Similarly, the manufacturer knows which karigar has made the piece. Alternatively, the corporate client or retail jeweller may choose to provide the manufacturer in gold i.e. the invoicing will show that the retailer has provided gold for manufacturing and the manufacturer has used the same gold.

Every jeweller has different payment terms, with 3 per cent GST on sale and 5 per cent GST on labour charges. Money is credited through net transfer, cheques and cash in usually 15-30 days.

5.3 Billing ProblemsOften the invoice of sale is not raised on the same day as supply of gold. Hence, it is common that price fixing of gold or the rate of gold (commonly known as “rate cutting” among manufacturers and jewellers) is not fixed on the same day of the supply but at a later time. For instance, the manufacturer sells jewellery worth 1kg, for which the current day price of which is assumed to be INR 30 lacs. However, if the invoice is raised on a later day, when the price of gold has fallen and has come down to say INR 29.5 lacs, then the manufacturer will lose INR 50,000 on the jewellery. The vice versa may happen too. The uncertainty largely affects their working capital (as they do require gold on a daily basis) and their inventory management. It also affects his productivity and that of the karigars with whom he works.


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On being asked about the experience with GST, manufacturers replied that GST has been largely good although initially hiccups did exist.

5.4 Gold Metal Loan (GML) and Its AdvantageGML proves to be an advantageous product. However, bulk buying of gold is difficult as interest rates are extremely high and import on consignment basis proves to be cheaper. Interest rates have usually been around 6 per cent although currently it varies from between 3.5-5 per cent. The usual formalities of GML are as follows:

a. Usually banks ask for a Fixed Deposit (FD) as a guarantee

b. For 3kg gold, the FD should be around INR 80 lakhs which is linked to GML. Usually it is a one time running FD. Alternatively property can be also be collateralised.

c. Banks also demand other details, such as, client details, details on who the buyers are, monthly average stocks maintained every month.

d. Banks only offer GML to manufacturers and not retail jewellers unless retail jewellers have an in house manufacturing unit.

e. GML is under CC limit

GML is mostly procured by the big manufacturers, although, it is the smaller manufacturers who need it most. More quantity of GML means lower rate of interest. Manufacturers believe that if GML rates were to come down between 1 and 2 per cent, and minimum quantity can be brought down to as low

as 1kg to 2 kg disbursal on a daily basis, then the volume of GML will increase to a large extent because the market will widen. It has been observed that GML is mostly a secured loan for banks, either with a FD or against a collateral. Alternatively manufacturers also avail of overdraft (OD) facility and are charged at 7-10 per cent. Cash credit limit is at 8 to 9 per cent.

5.5 Quality Check and HallmarkingManufacturers always check the quality when a karigar sends finished jewellery to them. Usually quality tests are undertaken by an XRF machine which costs anywhere between INR 35-40 lacs rupees. XRF machines are now easily available in India. Their margin of error is as low as 0.5 per cent.

Manufacturers are open to accepting responsibility for hallmarking. In fact, they believe, they will be on safer grounds if this done. If manufacturers are given the responsibility of hallmarking, jewellers can mark their jewellery separately through laser marking machines later.

There has been much debate upon who should assume responsibility of hallmarking and for any deviations in quality. Jewellers have always maintained that they are not in a position to do so since most times jewellery is made by the manufacturer. This seems fair. The only other option is for the manufacturer to hallmark the jewellery. This makes most sense for two reasons. First, the manufacturer does make the jewellery after all and hence it is best to test the quality at this stage rather than later. Second, any subsequent deviations in the quality can then be tracked easily.

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5.6 Export ProblemsExports are minimal. One of the problems of export is that export lots need to be at least 5kg. The current 1kg-2kg is not adequate. To claim duty drawback, the manufacturer/exporter needs to source gold only from nominated agencies. Moreover, most small manufacturers do not know how to approach the system or are intimidated by it. Even for those who do, the duty drawback takes anywhere between six months to a year. This flawed process locks up capital making it a failure from the start.

Availing the one time export certificate is an onerous task. It takes six to eight months to procure the one time export certificate. Even GJPEC is mostly helpless in such matters.

5.7 Consignment Delivery and Logistical ProblemsMovement of good is a problem for manufacturers. During movement, the consignment is checked and rechecked multiple times, irrespective of possession of bills and proper documentation. Harassment is common in both interstate and intrastate goods movements. This happens more in case the goods are carried by hand. Usually, logistic companies handle this problem, although instances of rent seeking are very common.

5.8 Cost of ExhibitionsOne of the biggest challenges is the cost of attending exhibitions. It is difficult for manufacturers to attend every exhibition that happen every year. It is also important to attend these, as new buyers also come

to these exhibitions. Manufacturers find it difficult to attend all as these involve time, money and human efforts. Hence, it is suggested that the government organise one or two huge national events/exhibitions which would be open to all and everyone can participate. Such programmes can be developed along the lines of the Global Auto Expo, Global Defence Expo etc. This should be organised by the Centre in collaboration one or two state governments every year.

5.9 Margins for the IndustryMargins of manufacturers varies between 2-5 per cent, whereas margins of retail jewellers varies between 15-20 per cent. In fact the retailers charge separately for stones and then add their margin to the jewellery.

Most manufacturers agreed to the idea of credit rating of the industry (retailers, wholesalers, manufacturers and karigars) and believe that it will be a good for the industry.

5.10 Lack of Skilled Karigars in the IndustryRetaining karigars and labour is a pressing issue. The karigar community unfortunately lacks unity and try and poach clients by offering lower making charges. This also leads to malpractices in business. Karigars are usually contracted by manufacturers on premises so that PF/Employee Insurance etc. can be avoided. Moreover, keeping karigars on roll also adds to overhead costs.


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6.1 Karigar Business – An Intro-ductionGoldsmiths (artisans), commonly known as karigars in India, are the life line of the gems and jewellery industry in India. Karigars are the makers of jewellery and other artisanal products and usually refrain from selling jewellery directly to retail customers. In karigar business, jewellery making is mostly a family business, usually taught by a father to his son. It has largely been a male dominated society with negligible female participation. Unfortunately, the art of jewellery making is now a dying art. In the last couple of years there has been a severe shortage of karigars in the gems and jewellery sector. Low profitability coupled with difficult working conditions have resulted in most youths of this generation to take up alternative professions. Moreover, most karigars

are usually reluctant to impart skills to individuals outside the family, although this has been taken care of by the Government with the help of various skill development initiatives in recent times.

6.2 Way it WorksKarigars are usually contracted by large jewellery manufacturers on job work basis. Typically, manufacturers have a set of contracted karigars from whom they procure jewellery. Karigars typically employ junior workers or sub karigar who work on contractual payroll of the karigar. On most occasion, the karigar is also responsible for providing his workmen with food, shelter and provisions as they work on very meagre salary. These workmen mostly work as understudy of older (more skilled) karigars. On an average, a freshman takes at least a year

6: Karigar Community

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to learn the art of jewellery making, if he works dedicatedly. For part time workers, it may takes more time depending on the person’s ability to learn.

6.3 Investment in BusinessA karigar typically needs to make an investment of INR 3-3.5 lacs initially to start his business, the majority of which goes into buying his melting and soldering machines. The karigar also needs chemicals such as concentrated nitric acid which comes for INR 8000 for 25 litres. Although karigars usually have bank accounts and few have credit cards too but taking a loan for work is mostly uncommon. On most occasions, they borrow from manufacturer as they feel taking a loan from banks will involve too much paperwork. Furthermore, a karigar can adjust the loan with his orders from the manufacturer over a period of time. Usually the raw material for making jewellery is supplied by the manufacturer or the retail-jeweller. The karigar obtains 24k pure gold from the manufacturer for making jewellery. Apart from that the karigar also buys and keeps small quantities of gold (varies from 100g to 200g) on a regular basis to account for the wastage of raw material while crafting jewellery from pure gold. Usually, the karigar sources this gold from bullion dealers and big retailers. Banks and formal institutions do not work for them as these institutions sell gold only in bulk quantity. It was found that in case the karigar buys grey market gold it is almost cheaper by INR 20 per gram when compared to the white market gold. This makes a difference of INR 20,000 on a kilo of gold. Digital transactions has been a boom for the karigars when there was shortage of cash in the recent past. However, as cash flow in the market increased, acceptance of digital transaction has decreased.

6.4 Procurement of Raw Material and Calculation of Karigar FeeOn procurement of gold from the manufacturer, the karigar first converts the 24k pure gold into 22k since jewellery cannot be crafted for 24k. The karigar then distributes the gold among his workers to make different parts of the jewellery. The experienced workers usually makes the intricate pieces while the newer ones usually makes less complicated parts or assist older workers. The karigar charges the manufacturer anywhere between INR 50-100 per gram of gold. During his work, a certain amount of raw gold is lost as ‘wastage’. The karigar then uses his own gold to account for the wasted gold in the piece of jewellery. This percentage of wastage is usually calculated between the manufacturer and karigar beforehand. The wastage calculations also includes the karigar’s profit margin. The wastage usually varies from 3 per cent to 5 per cent of which the junior karigars get 1.5 per cent to 2 per cent. The manufacturer doesn’t charge karigar for the wasted


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gold. In case the manufacturer doesn’t want any wastage to be included he pays for the additional gold that the kaarigar has added to the jewellery. Thus the total fee for a karigar can be calculated as follows:

If 1000g of 24K pure gold is supplied to the karigar, on conversion it would be 1086.95g of 22k gold (1000g/92% = 1000g/0.92 = 1086.95g)

Assuming wastage of gold at 3%, we get3% of 1086.95gm of 22k gold = (3/100)*1086.95g = 32.6085g

Monetary value of 32.6085g is multiplied by the value of gold.

Taking making charges at INR 100 per gram of jewellery we getINR 100/g*1086.95g

Hence, the total cost of making the jewellery isINR 100/g*1086.95g + monetary value of 32.6085 gm of gold

The karigar further adds 5 per cent Good and Services Tax (GST) on the total cost. Hence the total cost of the jewellery inclusive of all taxes, which the manufacturer has to pay to the karigar is[INR 100/g*1086.95g + monetary value of 32.6085 gm of gold] + 5% * [INR 100/g*1086.95g + monetary value of 32.6085 gm of gold]

When asked about GST, it was found that initially karigars faced problem for claiming the input benefits from GST since they had not applied for their GST registration. However, with passing time and subsequent GST registrations, they are now able to claim their input credits, thereby reducing

their costs substantially. Karigars are slowly and steadily adopting GST. This also means improved book keeping mechanisms, which also means the possibility of accessing credit through formal channels.

6.5 Challenges in the Business and RecommendationsThe business of jewellery making is now a dying art owing to various reasons. Few of the common issues have been poor working conditions, lack of proper infrastructure, rising medical and health issues, and absence of labour laws in the sector. It was found that most karigars work in residential areas where they are unable to set up proper chimneys and outlets. Due to this, they are forced to inhale the fumes from these acids and chemicals on a regular basis. Prolonged inhalation of these fumes leads them to have different respiratory problems at a very early age. Moreover, most karigars develop visual problems due to their nature of work. Back and muscle issues

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too are common among karigars. Apart from medical problems, karigars mostly come from poor educational background with limited or no knowledge about labour laws. This makes them vulnerable to unfair professional practices by other stakeholders. In fact karigars have limited recourse to help when unfair practices occcur. To top it all the karigar community in itself is fragmented and do not work in best interest of each other on most occasions.

It is to be understood that for the jewellery business to survive in India, it is important that the karigars community improves. To promote craftsmanship and ensure the survival of the community the working conditions of karigars be improved. Setting up of karigar parks and jewellery manufacturing hubs will help solve this problem to a large extent. The development of karigar parks should not just lie with the government but should be equally driven by the jeweller communities. Corporate Social Responsibility

(CSR) is one possible way. The Government should further focus on developing specific skilling programme that will impart training to fresh talents. The Government should also look to come up with customised insurance scheme for the karigars so that the same can be used in case of exigencies.

The industry in its part must look to provide better rates as making charges to the karigars. Bigger jewellers and manufacturer should possibly explore the options of reducing the margin on their profits so that it can be further passed down to the poor karigars. Moreover, instead of employing karigars on job work basis and contractual arrangement, bigger jewellers and manufacturers should explore the opportunity to employ karigars on full time employment basis so that the karigars can benefit under various employee schemes such as employee provident fund schemes, employee insurance scheme etc.

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7.1 Introduction of the Retail Jew-ellery Business in IndiaIn India, the retail jeweller is considered to be the main link between the entire gold value chain and the retail customers. The retail jeweller usually have showrooms and are responsible for selling the ultimate finished goods to domestic customers. There are an estimated 3.85 to 4 lakhs jewellery stores in India at present of which there are approximately 15,000 licensed BIS jewellers. There are approximately around 586 hallmarking centres in India. The organised retail jewellery business is estimated to be around 60 per cent to the total jewellery business in India, of which 32 per cent of the total business is done by large chain stores. Large chain stores are those businesses which have at least 8 to 10 stores in a city, state or around the country. The rest may be

considered as standalone stores, smaller chains and mid segment stores.

As per our discussions, about 80 per cent to 85 per cent of the retail jewellery businesses in southern states of India are tax compliant. This is followed by businesses from western India, eastern India and northern India. At present, to set up a retail jewellery store in any state a jeweller need to get a GST certification which is issued under HSN-7113/7114. For smaller jewellers, compliance is usually a problem

7.2 Sale and BillingThe sale of jewellery at a retail jewellery shop happens usually through cash, credit card, net transfer, digital transaction or on EMI basis. Apart from that exchange of old jewellery against new

7: Retail Jewellers

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jewellery also is a common means of buying jewellery. Many jewellers also run various schemes like gold accumulation plan in which a customer may pay instalments for eleven months and at the end of twelfth month may redeem the saving in the form of a jewellery of equal value. Personal loan can be also availed to buy jewellery. An interesting suggestion by the retailer jewellers has been to explore the facility of consumer finance companies so that jewellery may be bought with EMI as people consumer electronics.

The jeweller community has suggested that in tier 2 and tier 3, customers want cash in exchange of jewellery in case of emergency. Hence, it is suggested that sale of jewellery for cash in tier 2 and tier 3 cities may be increased from INR 10,000 to INR 50,000. Infact a bearer cheque makes sense from a traceability point of view too.

7.3 GST and TaxationSince gems and jewellery is a high value industry, compliance is always an issue with small jewellers. Most states ask for e-way bill, delivery challan and

GST invoice which is a problem with small jeweller. It is suggested that to bring small jewellers under GST exemption bracket, an allowance of 20g/day must be given or an annual allowance of (20*365) = 7,300g must be given. It is suggested that this is linked to the turnover definition of MSME issued by the MSME Ministry. While the turnover based definition for MSMEs makes sense for most sectors, it proves to be counterproductive for those sectors that deal in high value goods. The definition of what an MSME is for high value goods must be re-examined.

7.4 Prevention of Money Launder-ing Act (PMLA)Globally, dealing in cash for any high value products by an individual is restricted to USD 15000 or EUR 15000 for a single transaction per month as per FATF Rule. Anything above demands complete KYC of customer, irrespective of commodity. However, the Government of India has reduced the dealing amount to INR 50,000 for cash transactions of high value goods. Anything above this demands complete KYC, in case of cash transaction. Additionally, the bill copy and KYC documents have to be maintained for seven years, as per IT norms. All these details were to be filed and submitted to various authorities and mainly to the Financial Intelligence Unit. The accountability and responsibility of these documents lies with the jewellers who may or may not know be aware of the genuineness of KYC documents. Due to the high compliance costs, the applicability of PMLA to the sector was withdrawn.

7.5 HallmarkingAs per the new rules issued by the Bureau of Indian Standards, the onus of the purity of jewellery lies on


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the retail jewellers. As per jewellers, this cannot be the responsibility of only the retail jeweller because in most cases, jewellers buy finished goods from the manufacturer. Furthermore, there have also been instances of errors on the part of the hallmarking centres. Hence jewellers believe that the responsibility must be shared by all.

Jewellers suggest that the business has changed and jewellery are no more assembly lined. Whenever there is any kind of addition and reduction, then those items are hallmarked separately. There is truth to this argument and hence it is suggested that the responsibility of hallmarking rests with the manufacturer and hallmarking agency.

7.6 Reputation CrisisBy far the most difficult challenge for the jewellers has been to battle the negative perception that has mounted against them. Fraud is not limited to this sector alone. The nature of business does mean that the value of these frauds are high, but for the entire industry to be branded negatively affects the whole value chain. The persistence of cash in transactions is another problem. Inadequate bookkeeping by smaller jewellers also exposes them to a lot of scrutiny and suspicion. The jewellery community must work together to reduce the instance of cash transactions. This change has been witnessed in the purchase of consumer electronics too. GST will bring in a

greater degree of transparency. However, as already discussed, incentives must be provided to consumers to invoice their purchases. Financial institutions should also base their credit decisions on the basis of individual clients and not on the perceived reputation of the industry. As a sector that has the potential to contribute significantly to India’s employment, to exports, and to domestic growth it is imperative that the value chain work collectively towards fixing this reputation problem. This also means that policymakers must approach regulations for the industry from a different perspective. It is hoped that in the near future, and through the proposed gold policy, an ecosystem of trust is facilitated and not one of over regulation, that would drive business down.

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Annexure 1: Extract of table under CUS NTF NO. 25/1999 DATE 28/02/1999

S.No.Chapter or Heading or Sub-heading or tariff item [OLD Chapter]

Description of imported goods Description of finished goods

(1) (2) (3) (4)

LIST A

8. 28,29,32 38,39,68 74 .,

Copper plating salts, their i, brighteners, levellers, condi tioners, replenishers, stabi lizers; Black Oxide Coating (Microtech) solution/ salts, predip solution/salts, palladium catalyst solution/ salts

Printed Circuit Boards.

80. 71Gold in the form of wire, ribbon, preform of purity 99.99 % and above

Semi-conductor devices; Light Editing Diodes.

131 28,38,39Gold plating make up and replenisher solutions and salts; Resins for gold recovery

Semiconductor devices; LED/LED Displays; Connectors; PCBs Parts of connector

168 29,32, 38,39, 71

Dibutyl ether/Di-nbutyl ether Solvent; DMH Solvent; Printing Inks; Protective U.V.Lacquer; Dyes; Optical grade polycarbonate; Methyl Lactate; OFP; Cake Box; BOPP Film; Jewel box; Silver Sputtering Target

CD-R (unrecorded CD)

205. 71Silver copper alloy wire in dia upto 0.25 mm

Metal to ceramic brazing rings for GD tubes

225. 2834 9019 (i) Palladium Tetra Amine Sulphate Connectors


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Annexure 2:

Import of Industrial Products of PGM

Year HSN 2843 HSN 381512Total Import

(Rs. Lacs)Import Duty (BCD)on PGM

’08-09 50,855.32 12,559.07 63,414.39

’09-10 33,585.90 53,131.08 86,716.98 1-2%

’10-11 60,857.73 27,443.90 88,301.63 1-2%

’11-12 62,898.90 32,860.87 95,759.77 1-2%

’12-13 75,261.07 48,562.22 123,823.29Increase from 1-2% to 10% and

80:20 for Gold

’13-14 60,893.67 83,134.30 144,027.97 10% and 80:20 for Gold

’14-15 63,414.71 76,709.42 140,124.13 10% and 80:20 for Gold

’15-16 59,602.17 54,435.29 114,037.46 10% BCD

’16-17 82,787.53 59,052.46 141,839.99 10% BCD

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Annexure 2:

Year HSN 2843 HSN 381512

Total Import (Rs. Lacs)

Import Duty (BCD)on PGM

‟08-09 50,855.32 12,559.07 63,414.39 ‟09-10 33,585.90 53,131.08 86,716.98 1-2% ‟10-11 60,857.73 27,443.90 88,301.63 1-2% ‟11-12 62,898.90 32,860.87 95,759.77 1-2% ‟12-13 75,261.07 48,562.22

123,823.29 Increase from 1-2% to 10% and 80:20 for Gold

‟13-14 60,893.67 83,134.30 144,027.97 10% and 80:20 for Gold ‟14-15 63,414.71 76,709.42 140,124.13 10% and 80:20 for Gold ‟15-16 59,602.17 54,435.29 114,037.46 10% BCD ‟16-17 82,787.53 59,052.46 141,839.99 10% BCD

0.00

20,000.00

40,000.00

60,000.00

80,000.00

100,000.00

120,000.00

140,000.00

160,000.00

‟08-09 ‟09-10 ‟10-11 ‟11-12 ‟12-13 ‟13-14 ‟14-15 ‟15-16 ‟16-17

Import of Industrial Products of PGM

Total Import(Rs. Lacs)

ease of doing business in the

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